Re Denley [1969]

Case concerned piece of land to be used as a
recreation ground ‘primarily for the benefit of the employees of the company’
Goff J:
‘The beneficiary principle of Re Astor is confined to purpose or object trusts which are abstract
or impersonal … Where … the trust, though expressed as a purpose, is directly
or indirectly for the benefit of an individual or individuals … it is generally
outside the mischief of the beneficiary principle’.